Industry Exposure Trends Voluntary Blood Lead Reduction Programmes The European Battery Industry

1. Industry Exposure Trends Voluntary Blood Lead Reduction Programmes The European Battery Industry Prague, 19 June 2013 Michel Baumgartner, EU Affairs Manager

2. EuropeanBatteryIndustry EUROBAT BatteryManufacturersprovide over 25,000 direct jobs to Europe 10,000 staff directly involved in Lead-based battery manufacturing

3. Battery Manufacturers Membership

4. Contents • 1° Why a Blood Lead Programme? • a. Rationale • b. DNEL / OELs • c. Results of previous EUROBAT Blood Lead Programme • 2° (New) Provisions of EUROBAT Blood Lead Programme • a. Objectives • b. Guidelines • c. Specific Provisions - Examples • d. Enforcement & Reporting

5. 1.a. Why a Blood Lead Programme : The Rationale • A duty for continuousimprovement • Technicalprogress in industryisfasterthanlegislation • Transparent dialogue withregulators – Evidence thatindustrycanbe a crediblepartner and deliverresults on itsown • EUROBAT Blood Lead Programme in place since 2001. • Objective wasto reduceblood lead levels for all employees to 50µg/dl blood and to 30 µg/dl for femaleemployees in childbearingcapacity. • Objectives revised in 2006. • Target lowered to 40µg/dl for all employees (unchanged for femaleemployees in chilbearingcapacity) by 12/2007.

6. 1.b OELs / DNEL • “The Commission services are of the view that OELs and DNELs (for both the same • duration and the same route of exposure) may co-exist, and in some circumstances • may apply simultaneously to some work activities. In certain cases, where the guidance allows the registrant to use OEL instead of deriving DNEL, the problem of two different values would not arise. In other cases, it is the Commission's view that, in principle, the lowest level should be complied with by the employer. The binding OEL needs to be always complied with by the relevant employer. In cases when the DNEL is lower than the OEL, the compliance with DNEL is based on the premise that the registrant could not use OEL instead of deriving DNEL for the same exposure route and duration, as he has obtained new scientific information which indicated that the OEL does not provide the appropriate level of protection.” • European Commission • General Report on REACH, page 7 • 5 February 2013

7. 1.c Results EUROBAT Blood Lead Programmes 2001 and 2006 Limited improvementsince 2008, under national OELs but somestillabove DNEL (<40µg/dl for males and <10µg/dl for females).

8. 1.d Results REACH Lead Consortium Survey – BatteryManufacturing Limited improvementsince 2008, under national OELs but somestillabove DNEL (<40µg/dl for males and <10µg/dl for females).

9. 2° (New) Provisions of EUROBAT Blood Lead Programme • 2.a: Objective • All employeesbelow 30µg/dl bloodat the end of 2016. Takingintoaccount 10µg/dl limit for femaleemployees in chilbearingcapacity. • 2.b: Guidelines • Definitions / specifications: monitoring frequency, removal & return levels… • Catalogue of best practices to achieve objectives: • TechnicalControls • Personal and generalhygiene • Training and counselling

10. 2.c. Specific Provisions - Examples • Monitoring Frequency: All employeesundermedical surveillance to betestedat least every 6 months. EmployeeswithPbBunder 15µg/dl or working in e.g administration canbetested once per year. • Removallimit: 30µg/dl as from 2015. Return level: 25µg/dl. Femaleemployees in childbearingcapacitywithPbB over 10µg/dl to beemployed in areas of non-significantexposure(where no Pb processingtakes place). • Reporting: once per year to EUROBAT for annualbatteryindustryblood Lead data (improved questionnaire per plant) • Plant design / LockerRooms:

11. 2.d. Enforcement and Reporting • Adherencecompulsory for EUROBAT members • Differentsteps in enforcement – up to possible exclusion • Support procedure for members not reaching objectives • Inclusion of facilities in all EMEA but flexibility for MEA region • Open to non-members • Improvedreporting format for verifyingcompliancewith the programme

12. THANK YOU!